For more than a decade, the College has worked with our partners to modernize Medicare’s outdated allergy immunotherapy billing policies. Together, we successfully persuaded Medicare to cover the buildup phase of allergy shots. Now, we have our best opportunity yet to finish the job.
In the proposed 2027 Medicare Physician Fee Schedule, CMS acknowledges many of the concerns ACAAI has raised, including that Medicare’s outdated definition of a 1cc aliquot/dose, has created confusion and has increasingly been adopted by commercial insurers and Medicaid plans. The agency recognizes that its current policy has created confusion and that differences between Medicare and standard allergy practice have contributed to barriers to patient care.
Now CMS is asking for more evidence—and they need to hear from you. This is our opportunity to show that this is not just an ACAAI issue; it is an issue affecting allergists and patients across the country. Every allergist. Every practice. Every local, state, and regional allergy society. All will be impacted! All allergists and other qualified healthcare professionals can submit comments. The deadline is Sept. 14. We’ve heard from members who’ve already submitted comments to CMS… please add your voice!
Download this sample comment letter as your starting point. It is long, but there are many points that need to be made. Feel free to submit it exactly as written, adding your personal data in the areas highlighted in red on the template. A submitted general/template letter is far better than no letter at all. But, if possible, personalize it. Describe why immunotherapy matters to your patients. Share an example of a patient whose life was changed by allergy shots, or whose care was delayed or denied because of reimbursement or insurance policies.
If writing isn’t your strength, let AI help. Tools such as ChatGPT or Claude can quickly turn the sample letter into a personalized comment. If you don’t use AI, ask a staff member in your office who does to help you.
The deadline for comments is Sept. 14, but don’t put it off! Do it today (or at least this week!). You can submit your comment letter via regular mail or electronically. CMS has opened the door. Together, let’s make sure they hear allergy’s voice.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
